RECEIVE8
UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
Postal Rate and Fee Changes,
FEB 10
3 17
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Docket No. R2000-1
2000)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS MICHAEL W. MILLER (OCAIUSPS-T24-1-4)
February lo,2000
Pursuant
Commission,
requests
to sections
26 and 27 of the Rules of Practice
the Office of the Consumer
for production
OCA/USPS-1-14
of documents.
Advocate
Instructions
hereby submits interrogatories
included
submitted,
JQ..Au!
TED P. @RARDEN
”
Director
Office of the Consumer Advocate
SHELLEY
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
S. DREIFUSS
and
with OCA interrogatories
dated January 24, 2000, are hereby incorporated
Respectfully
of the Postal Rate
by reference.
2
Docket No. RZOOO-1
OCAIUSPS-T24-I,
(4
Please refer to your testimony at page 9, lines 9-14.
Please define the term “marginal
(volume variable)
productivity”
as you use it
there.
W
Please provide a representative
the information
(4
contained in USPS-LR-I-107
What effect does the marginal
differences
calculation
productivity
you display in Appendix
of a marginal productivity
and USPS-T-17,
Table 1.
have on the magnitude
I of your testimony?
value using
of the cost
Please describe
fully
and provide an example.
OCA/USPS-T24-2.
Please refer to your testimony
define “non-worksharing
worksharing
nonworksharing
at page
fixed costs are used to
savings.
Is that interpretation
rationale
Also refer to your testimony
You appear to state there that nonworksharing
calculate worksharing
(a)
fixed” costs as those that “are not affected at all by the types of
activities covered in this testimony.”
10, lines 25-29.
at page 4, lines 18-20, where you
correct?
fixed costs.
for including
If not, please state your position with respect to
If OCA’s understanding
nonworksharing
is correct, then state your
fixed costs in a calculation
of the cost
savings resulting from worksharing.
(b)
Also explain whether your position is consistent with the Commission’s
Docket No. MC951
that inclusion of “cost differences
prebarcoding
are inconsistent
Commission’s,
signals to potential
result of worksharing.”
producers
unrelated to presorting
with the Postal Service’s,
intent that these workshare
category
opinion in
differentials
and
as well as the
send accurate
of the costs that the Postal Service avoids as a
Docket No. MC2000-2
OCALJSPS-T24-3.
rationale
3
Please refer to your testimony
for dividing
the difference
between
at page 13, lines 2530.
(“Benchmark
Worksharing
Proc Unit Costs + Delivery Unit Costs”) and (“Rate Category
Proc Unit Costs + Delivery Unit Costs”) by (“Worksharing
What is the
Related
Worksharing
Mail
Related Mail
Related Savings”)?
Explain
fully.
OCA/USPS-T24-4.
analysis
In the instant proceeding,
of mail processing
some mail processing
costs that leads the Service to conclude
cost volume variabilities
For the purpose of developing
worksharing
A presort rate categories,
ranging volume variabilities
so, explain
that the costs of
activities vary less than 100 percent with volume.
these mail processing
Standard
the Postal Service appears to present an
how your
are significantly
does your analysis
takes
less than 100 percent.
related savings for First-Class
for different cost pools?
analysis
In some cases,
these
presort and
reflect the differing and wide-
If not, why not?
wide-ranging
volume
(Explain fully.)
variabilities
If
into
account.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served
participants
of record in this proceeding
in accordance
Stephanie
Washington, D.C. 20268-0001
February IO,2000
the foregoing
with section
S. Wallace
document
upon all
12 of the rules of